Stolt Groenland Ulsan, Republic of Korea - GOV.UK
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ACCIDENT REPORT INVESTIGATED BY THE MAIB ON BEHALF OF THE CAYMAN ISLANDS GOVERNMENT Report on the investigation of the cargo tank explosion and fire on board the chemical tanker Stolt Groenland Ulsan, Republic of Korea 28 September 2019 SERIOUS MARINE CASUALTY REPORT NO 9/2021 JULY 2021
This investigation was carried out by the UK Marine Accident Investigation Branch (MAIB) on behalf of the Cayman Islands Government in accordance with the Memorandum of Understanding between the MAIB and the Red Ensign Group Category 1 registries of Isle of Man, Cayman Islands, Bermuda and Gibraltar. Extract from The Cayman Islands Merchant Shipping (Marine Casualty Reporting and Investigation) Regulations, 2018 – Regulation 4: “The sole objective of a marine safety investigation into an accident under these Regulations shall be the prevention of future accidents through the ascertainment of its causes and circumstances. It is not the purpose of a marine safety investigation to determine liability nor, except so far as is necessary to achieve its objective, to apportion blame.” NOTE This report is not written with litigation in mind and, pursuant to Regulation 22 of The Cayman Islands Merchant Shipping (Marine Casualty Reporting and Investigation) Regulations, 2018, shall be inadmissible in any judicial proceedings whose purpose, or one of whose purposes, is to attribute or apportion liability or blame. All MAIB publications can be found on our website: www.gov.uk/maib Front cover image courtesy of Lappino (shipspotting.com) For all enquiries: Marine Accident Investigation Branch Maritime Authority of the Cayman Islands First Floor, Spring Place Breezy Castle Unit 1 105 Commercial Road 125 Owen Roberts Drive Southampton P.O. Box 2256 SO15 1GH Grand Cayman KY1-1107 United Kingdom www.cishipping.com/contact-us Email: maib@dft.gov.uk Telephone: +44 (0)23 8039 5500 Press enquiries during office hours: +44 (0)1932 440015 Press enquiries out of hours: +44 (0)300 7777878 © Crown copyright, 2021 You may re-use this document/publication (not including departmental or agency logos) free of charge in any format or medium. You must re-use it accurately and not in a misleading context. The material must be acknowledged as Crown copyright and you must give the title of the source publication. Where we have identified any third party copyright material you will need to obtain permission from the copyright holders concerned.
CONTENTS GLOSSARY OF ABBREVIATIONS AND ACRONYMS SYNOPSIS 1 SECTION 1 – FACTUAL INFORMATION 2 1.1 Particulars of Stolt Groenland and accident 2 1.2 Narrative 3 1.2.1 Passage and cargo discharge 3 1.2.2 Explosions 7 1.2.3 Emergency response 7 1.3 Environmental conditions 10 1.4 On-site investigation 10 1.5 Damage 10 1.6 Onboard records 11 1.7 Styrene monomer 12 1.7.1 Description 12 1.7.2 Polymerisation 16 1.7.3 Polymerisation inhibitors 16 1.8 Cargo system 18 1.9 Loading in Houston 18 1.9.1 Planning and documentation 18 1.9.2 The cargo 20 1.9.3 Styrene and inhibitor mixing 21 1.9.4 Styrene sampling 21 1.10 Cargo temperature changes during the voyage 23 1.11 Crew 25 1.11.1 General 25 1.11.2 Master 25 1.11.3 Chief officer (Ulsan) 25 1.11.4 Chief officer (loading and voyage) 25 1.11.5 Voyage routines 25 1.12 Cargo management ashore 26 1.13 Onboard cargo procedures 27 1.13.1 Planning and stowage 27 1.13.2 Cargo monitoring 27 1.14 IBC Code 27 1.15 Shipping industry guidance 29 1.15.1 Tanker Safety Guide 29 1.15.2 Chemical Distribution Institute Guidance 29 1.16 Storage and handling guidance 30 1.16.1 Styrene Monomer: Safe Handling Guide (2018) 30 1.16.2 Safe handling sheets 31 1.16.3 Safety data sheets 32 1.17 Recent inspections, audits and vetting 32 1.18 Yeompo Quay 32 1.19 Styrene monomer accidents and incidents 33 1.19.1 Stolt Focus 33 1.19.2 Other maritime accidents 34 1.19.3 Shore-based accidents 34 1.20 Styrene sample and overall analysis results 35
SECTION 2 – ANALYSIS 37 2.1 Aim 37 2.2 Explosion and fire mechanisms 37 2.3 Initiation of polymerisation 37 2.4 Heat transfer 38 2.5 Polymerisation inhibitor mixing 39 2.6 Polymerisation inhibitor depletion 39 2.7 Cargo stowage 40 2.8 Temperature monitoring 42 2.9 Action in the event of polymerisation 43 2.10 Fire-fighting 44 2.11 Stolt Focus incident 44 SECTION 3 – CONCLUSIONS 46 3.1 Safety issues directly contributing to the accident that have been addressed or resulted in recommendations 46 3.2 Safety issues not directly contributing to the accident that have been addressed or resulted in recommendations 47 3.3 Other safety issues not directly contributing to the accident 47 SECTION 4 – ACTION TAKEN 48 4.1 MAIB actions 48 4.2 Actions taken by other organisations 48 SECTION 5 – RECOMMENDATIONS 49 FIGURES Figure 1: Ofdjell terminal and Yeompo Quay, Ulsan Figure 2: Cargoes remaining following discharge in Ulsan Figure 3: CCTV still showing vapour release from 9S p/v valve Figure 4: CCTV still showing tank rupture and vapour release Figure 5: CCTV still showing vapour ignition Figure 6: Fireball at Ulsan bridge Figure 7: Bow Dallian main deck with burned styrene deposits Figure 8: Styrene residue sample Figure 9: Overalls from Bow Dallian crewman Figure 10: 9S heating control valves
Figure 11: Aerial view of main deck and location of 9S Figure 12: 9S tank rupture Figure 13: 9S access hatch Figure 14: Midships deckhouse Figure 15: Accommodation interior Figure 16: Accommodation front Figure 17: Cargo temperatures recorded on the VDR Figure 18: Certificate of Inhibitor Final sample analysis results 9S Styrene Monomer Temperature 20-28 September TABLES Table 2: Temperatures of cargoes discharged in Kobe and Ulsan Table 4: TBC depletion in styrene (if stored under air) Table 8: Calculated TBC depletion using figures provided in the Plastics Europe Styrene Monomer: Safe Handling Guide (2018)
GLOSSARY OF ABBREVIATIONS AND ACRONYMS 2/O - Second officer 3/O - Third officer ACA - American Cargo Assurance AIS - Automatic identification system CCR - Cargo control room CDI - Chemical Distribution Institute C/O - Chief officer ERT - Emergency Response Team HMD - Hexamethylenediamine IBC Code - International Code for the Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk IMO - International Maritime Organization Ineos - Ineos Styrolution America LLC INTERTANKO - International Association of Independent Tanker Owners iStow - iStow Tanker cargo stowage software KMST - Korea Maritime Safety Tribunal LPD - LPD Lab Services Limited m - metre m³ - cubic metres mb - millibar MARPOL - International Convention for the Prevention of Pollution from Ships MCO - Marine Compliance Officer OS - Ordinary seaman OTK - Odfjell terminal in Ulsan, Republic of Korea ppm - parts per million PTZ - Phenothiazine p/v - Pressure/vacuum SDS - Safety Data Sheet SHC - Specific Heat Capacity SMS - Safety Management System SOLAS - International Convention for the Safety of Life at Sea 1974, as amended
ST B503 - Shore Tank 503 STCW - International Convention on Standards of Training, Certification and Watchkeeping for Seafarers 1978, as amended (STCW Convention) Stolt - Stolt Tankers B.V. t - tonne TBC - 4-tert-Butylcatechol TEA - Triethanolamine TSG - Tanker Safety Guide UTC - Universal co-ordinated time VCR - Voyage cargo report VDR - Voyage data recorder Voranol - Glycerol, propoxylated and ethoxylated YMP3 - Yeompo Quay, berth 3 TIMES: all times used in this report are UTC + 9 unless otherwise stated.
SYNOPSIS On 28 September 2019, a cargo tank containing styrene monomer on board the Cayman Islands registered chemical tanker Stolt Groenland ruptured causing an explosion and fire. The tanker was moored alongside a general cargo berth in Ulsan, Republic of Korea and the Singapore registered chemical tanker Bow Dalian was moored outboard. The ignition of the styrene monomer vapour resulted in a fireball, which reached the road bridge above. Both vessels were damaged, and two crew suffered minor injuries. Fifteen emergency responders were injured during the fire-fighting, which lasted for over 6 hours. The rupture of the styrene monomer tank resulted from a runaway polymerisation that was initiated by elevated temperatures caused by heat transfer from other chemical cargoes. The elevated temperatures caused the inhibitor, added to prevent the chemical’s polymerisation during the voyage, to deplete more rapidly than expected. Athough the styrene monomer had not been stowed directly adjacent to heated cargo, the potential for heat transfer through intermediate tanks was not fully appreciated or assessed. Critical temperature limits had been reached before the vessel berthed under the road bridge in Ulsan. The tanker’s crew did not monitor the temperature of the styrene monomer during the voyage, and therefore were not aware of the increasingly dangerous situaution. A similar dangerous styrene monomer polymerisation incident had occurred a couple of weeks ealier on board another Stolt Tankers B.V. ship, Stolt Focus. The heat generated by the polymerisation process was noticed before the critical runaway temperature was reached. The styrene momomer cargoes on board both tankers was loaded at a similar time from the same tank in Houston and were exposed to similar environmental conditions. The incident on board Stolt Focus was not reported to the ship’s Flag State or other masters in the Stolt Tankers B.V. fleet. Following the accident, the Ministry of Oceans and Fisheries, Republic of Korea, prohibited ship-to-ship transfer operations for dangerous cargo on general cargo berths in Ulsan. Stolt Tankers B.V. took immediate action to ensure that the temperatures of all cargoes carried on board its ships were monitored and reported to its shore management. It also took steps to enhance crew awareness on the hazards of inhibited and heat sensitive cargoes. The company is developing technological and administrative initiatives to assist with the safe stowage and monitoring of heat sensitive cargoes. A recommendation has been made to Stolt Tankers B.V. aimed at ensuring the wider marine chemical sector benefits from the lessons learned from the Stolt Focus incident and research initiatives that were carried out as a result of this accident. Recommendations have also been made to the Cayman Island Shipping Registry, the Chemical Distribution Institute and Plastics Europe (Styrene Producers Association). These are intended to assist in ensuring that the guidance provided in certificates of inhibitor and styrene monomer handling guides is consistent and achievable given the limitations of equipment and testing facilities on board ships. 1
SECTION 1 – FACTUAL INFORMATION 1.1 PARTICULARS OF STOLT GROENLAND AND ACCIDENT SHIP PARTICULARS Vessel’s name Stolt Groenland Flag Cayman Islands Classification society Det Norske Veritas Germanischer Lloyd IMO number/fishing numbers 9414072 Type Chemical/products tanker Registered owner Stolt Tankers B.V. Manager(s) Stolt Tankers B.V. Construction Steel Year of build 2009 Length overall 182.72m Beam 32.24m Gross tonnage 25881 Deadweight 43478 Minimum safe manning 17 Authorised cargo Chemicals and oil products in bulk VOYAGE PARTICULARS Port of departure Kobe, Japan Port of arrival Ulsan, Republic of Korea Type of voyage International Cargo information Chemicals in bulk 27117 tonnes Manning 25 MARINE CASUALTY INFORMATION Date and time 28 September 2019 at 1050 Type of marine casualty or incident Serious Marine Casualty Location of incident Ulsan, Republic of Korea Place on board Cargo tanks and deck Injuries/fatalities 2 crew suffered minor injuries (1 on board Stolt Groenland and 1 on board Bow Dalian). 15 shore workers/officials were also reported to have been injured. The severity of their injuries is not known Damage/environmental impact Toxic vapour released to atmosphere Ship operation Moored alongside Voyage segment Moored alongside External & internal environment Daylight. Air temperature: 24ºC Wind: Light airs. Humidity 93% Persons on board 26 2
1.2 NARRATIVE 1.2.1 Passage and cargo discharge Between 2 and 17 August 2019, Stolt Groenland, a Cayman Islands registered chemical tanker operated by Stolt Tankers B.V. (Stolt), loaded 20 different chemical cargoes from terminals in Texas, USA. Cargo was carried in 37 of the tanker’s 39 cargo tanks for delivery in various ports in the Far East (Table 1). Tanks 3 Port (3P), 7 Starboard (7S), 8P, 9P, 10P, and 11P contained heated cargoes. The temperatures of the cargoes in 3P and 7S were required to be maintained at between 40ºC and 45ºC, and the temperatures of the cargoes in 8P, 9P, 10P, and 11P (Hexamethylenediamine (HMD)), the last cargo to be loaded, had to be maintained at between 45°C and 50°C. The temperature of the HMD at loading was 61°C. KEY: P = port C = centre S = starboard Tank number Liquid quantity/98%tank capacity (m³) Heated cargo Styrene monomer Chemical IMO name Port of loading/discharge Loaded/carriage temperature (ºC) 1P: 502/890 - Butyl cellosolve 1C: 1272/1377- Acrylonitrile 1S: Adiponitrile - 870/890 Texas City/Singapore Point Comfort/Taiwan Houston2/Ulsan 31/ambient 29/ambient 31/ambient 2P: 1259/1279 - Adiponitrile 2C: 1191/1326 - Acrylonitrile 2S: 1269/1279 - Ethylene dichloride Houston2/Ulsan Odfjell Point Comfort/Taiwan Freeport/Ulsan terminal 29/ambient 30/ambient 32/ambient 3P: 432/620 - Diglyceryl ether of 3C: 578/596 - Adiponitrile 3S: 585/620 - Isobutyl acetate bisphenol A Houston2/Ulsan Odfjell Houston2/Ulsan Freeport/Ulsan 32/ambient 31/ambient 42/40-45 4P: 264/352 - Dichloromethane 4C: 205/273 - Dichloromethane 4S: 262/352 - Dichloromethane Freeport/Ulsan Freeport/Ulsan Freeport/Ulsan 37/ambient 35/ambient 35/ambient 5P: 578/663 - Ethylene glycol 5C: 587/610 - Adiponitrile 5S: 443/663 - Toluene diisocyanate monobutyl ether Houston2/Ulsan Odfjell Houston1/Kobe Houston2/Taiwan 31/ambient 33/ambient 33/ambient 6P: 1973/2157 - Styrene 6C: 1842/2085 - Styrene monomer 6S: 2110/2157 - Adiponitrile monomer Houston1/Taiwan Houston2/Ulsan Houston1/Taiwan 17/ambient (inhibited - must not be 31/ambient 17/ambient (inhibited - must heated) not be heated) 7P: 916/1212 - Ethox polyhydric 7C: 528/1149 - Poly(2-8) alkylene glycol 7S: 462/1212 - Diglycidyl ether of alcohol monoalkyl(C1-C6) ether bisphenol A Houston2/Ulsan Texas City/Singapore Freeport/Ulsan 39/ambient 31/ambient 50/40-45 8P: 599/663 - 8C: 494/610 - Triethanolamine 8S: 595/663 - Noxious liquid NF (5) Hexamethylenediamene Texas City/Ulsan NOS (Alfol 610) (HMD) 40/ambient Houston2/Kobe Houston2/Ulsan 31/ambient 61/45-50 9P: 2092/2157 - HMD 9C: 1953/2085 - Adiponitrile 9S: 1966/2157 - Styrene monomer Houston2/Singapore Houston2/Ulsan Houston1/Taiwan 61/45-50 34/ambient 17/ambient (inhibited - must not be heated) 10P: 1124/1212 - HMD 10C: 1147/1149 - Glycerol, propoxylated 10S: 955/1212 - Methyl methacrylate Houston2/Ulsan and ethoxylated (Voranol) Houston2/Taiwan 61/45-50 Freeport/Ulsan 32/ambient (inhibited - must not 32/ambient be heated) 11P: 314/324 – HMD 11C: 299/329 – Ethanolamine 11S: 321/324 - Glycerol, propoxylated Houston2/Singapore Texas City/Kobe and ethoxylated(Voranol) 58/45-50 33/ambient (55 maximum) Freeport/Ulsan 33/ambient 12P: 0/1383 - Empty 12C: 1346/1347 - Ethylene dichloride 12S: 0/1383 - Empty Freeport/Ulsan 32.5/ambient 13P: 1887/1889 - Ethylene 13C: 13C 13S: 1886/1889 - Ethylene dichloride dichloride 1944/1954 - Ethylene dichloride Freeport/Ulsan Freeport/Ulsan Freeport/Ulsan 32/ambient 31/ambient 33/ambient Table 1: Cargo stowage on departure from Houston on 17 August 3
The cargoes also included 5245t of styrene monomer, loaded on 7 and 8 August, which was divided among cargo tanks 6P (1789t), 6 Centre (6C) (1671t), and 9S (1785t), to which a polymerisation inhibitor had been added (see Section 1.7.2). The tanker sailed for passage to Japan on 17 August. Between 22 and 24 September, Stolt Groenland’s cargo tanks 5S, 8C (part cargo), 8S and 11C were discharged to barges while the vessel was at anchor off Kobe, Japan. The vessel then sailed to Ulsan, Republic of South Korea, where six tanks containing adiponitrile were discharged at the Odfjell terminal (OTK) on 26 and 27 September. During discharge on 26 September, the tanker’s chief officer (C/O) handed over to his relief, who had arrived shortly after the vessel moored alongside. The off-going C/O departed the vessel at about 1500. During the afternoon of 27 September 2019, Stolt Groenland shifted from the OTK to Yeompo Quay, berth 3 (YMP3) underneath the Ulsan Bridge (Figure 1). The tanker moored starboard side to the quay and during the evening, a cargo of Voranol was discharged from cargo tanks 10C and 11S to Stolt Voyager via ship-to-ship transfer. On completion, Stolt Voyager moored ahead of Stolt Groenland. The temperatures of the cargoes discharged in Kobe and at OTK recorded on the ullage reports are shown in Table 2. The attending cargo surveyor in Ulsan noticed that the temperature of the adiponitrile in 9C (48.8ºC) was elevated, but as it remained within the charterer’s specified maximum temperature of 50ºC, he did not discuss this with the C/O and no action was taken. The distribution of the cargoes remaining on board Stolt Groenland following the discharges in Kobe and OTK is shown at Figure 2. Discharge Date Tank Cargo Place Temperature 22-23 Sep 5S Toluene Kobe, Japan 33.2°C 22-23 Sep 8C (part cargo) Triethanolamine (TEA) Kobe, Japan 43.6°C 22-23 Sep 8S ALFOL Kobe, Japan 39.1°C 22-23 Sep 11C MEA Kobe, Japan 48.2°C 26-27 Sep 1S ADIPONITRILE OTK, Ulsan 27.2°C 26-27 Sep 2P ADIPONITRILE OTK, Ulsan 30.0°C 26-27 Sep 3C ADIPONITRILE OTK, Ulsan 29.8°C 26-27 Sep 5C ADIPONITRILE OTK, Ulsan 30.5°C 26-27 Sep 6S ADIPONITRILE OTK, Ulsan 31.9°C 26-27 Sep 9C ADIPONITRILE OTK, Ulsan 48.8°C 27 Sep 10C VORANOL YMP3, Ulsan 46.0°C 27 Sep 11S VORANOL YMP3, Ulsan 38.4°C Table 2: Temperatures of cargoes discharged in Kobe and Ulsan 4
Satellite image courtesy of Google Maps Yeompo Quay Ofdjell terminal Figure 1: Ofdjell terminal and Yeompo Quay, Ulsan 5
6 PORT Heated (3P, 7S, 8P, 9P, 10P and 11P) Empty (1S, 2P, 3C, 5C, 5S, 6S, 8S, 9C, 10C, 11C, 11S, 12P and 12S) AFT FORWARD Styrene monomer (6P, 6C and 9S) STARBOARD Other cargo (the tanks that are left) AFT PORT FORWARD W.B.TANK No.7 W.B.TK No.6P W.B.TANK No.5P HEELING TANK PS W.B.TANK No.3P W.B.TANK No.2P W.B.T AN K No.1 13P 12P 10P 8P 7P 4P 3P 11P 9P 6P 5P 2P 1P 4C 13C 12C 11C 10C 9C 8C 7C 6C 5C 3C 2C 1C CD1 CD4 CD3 CD2 11S 2S 1S 13S 12S 10S 9S 8S 7S 6S 5S 4S 3S o.1 A NK N W.B.T W.B.TANK No.7 W.B.TANK No.6S W.B.TANK No.5S HEELING TANK STB W.B.TANK No.3S W.B.TANK No.2S STARBOARD Cofferdam Cofferdam Figure 2: Cargoes remaining following discharge in Ulsan
1.2.2 Explosions At about 0600 on 28 September, the Singapore registered chemical tanker Bow Dalian was secured alongside Stolt Groenland’s port side. The purging of Bow Dalian’s cargo tanks with nitrogen supplied from shoreside vehicles was then started in readiness for a ship-to-ship cargo transfer with Stolt Groenland. At 1043, vapour started to release from the pressure/vacuum (p/v) relief valve for Stolt Groenland’s 9S cargo tank (Figure 3). About 2 minutes later, the tank’s high-level alarm (indicating that the level in 9S cargo tank had reached 95%) activated the warning siren and strobe light on the bridge front. The warning indicators were noticed by the ordinary seaman (OS) on gangway watch, and he immediately notified the third officer (3/O), the on-watch deck officer, via hand-held radio. The 3/O was working in the master’s office and went to the unmanned cargo control room (CCR) to investigate. The OS’s radio transmission was also heard by the C/O, and he joined the 3/O in the CCR. Shortly afterwards, the high-high-level siren on the bridge front sounded, indicating that the level in 9S cargo tank had increased to 98%. The alarm was again reported by the OS. The C/O and 3/O saw from the cargo monitoring system that the pressure inside 9S cargo tank was 1340mb, and observed it rise quickly to 2000mb. At 1050, two explosions occurred in rapid succession in way of the vessel’s cargo manifold (Figure 4). The second explosion ignited the released styrene monomer vapour (Figure 5) and the resulting fireball passed very close to the road bridge above the quay (Figure 6). It also ignited vapours released from the 9S and 9C p/v valves. 1.2.3 Emergency response Stolt Groenland On board Stolt Groenland, the force of the second explosion blew the gangway watchman over the starboard side guardrails on the main deck. The OS initially held on to one of the rails, but he was soon forced to let go due to the heat from the fire. He fell into the water between the quay and the vessel, but he was able to climb over a fender and on to the quay. The C/O activated the fire alarm and the tanker’s crew mustered at their fire stations. The C/O also activated the deck foam monitor system and directed the port monitor toward the cargo manifold. The 3/O did likewise with the starboard monitor. However, the master soon ordered everyone to the lifeboat station on the boat deck due to the intensity of the fire and the thick black smoke. The crew used the freefall lifeboat to abandon the tanker. Bow Dalian Following the explosions, Bow Dalian’s C/O activated the vessel’s emergency alarm and the deck foam fire extinguishing system. He and the master also directed the monitors toward Stolt Groenland’s main deck and cargo manifolds. The crew then abandoned ship via a rope ladder on the vessel’s port side on to Korea Coast Guard vessels, which had arrived to assist. 7
Vapour release Figure 3: CCTV still showing vapour release from 9S p/v valve Vapour explosion from tank 9S Figure 4: CCTV still showing tank rupture and vapour release Figure 5: CCTV still showing vapour ignition 8
Image courtesy of @803_Gorani (Twitter) Figure 6: Fireball at Ulsan bridge Stolt Stolt was informed of the explosions and fire on board Stolt Groenland by a marine compliance officer (MCO) who was on board Stolt Voyager, and immediately activated its Emergency Response Team (ERT) in the Netherlands. The ERT communicated with its MCO via telephone and ‘WhatsApp messenger’ and established that Stolt Groenland’s crew were safe. At 1528, the ERT were informed of a further explosion toward the tanker’s accommodation. However, at 1612, it received a report that the fire had dampened down and that no flames were visible. Shortly afterwards, the fire was reported to have been extinguished, although there was still smoke in the accommodation. Stolt’s protection and indemnity insurers, Gard, appointed the Netherlands based salvors Ardent, to assist Stolt’s emergency response team. It also e-mailed its fleet to check styrene monomer cargoes that were being carried. This was later backed up by fleet Flash Report no.2019/08 highlighting the precautions required when styrene monomer is carried. Local emergency services Local fire brigade shore appliances arrived at YMP3 at 1101 and started to fight the fire. Korea Coast Guard fire-fighting tugs and launches assisted and towed Bow Dalian to a berth clear of Yeompo. A total of 726 emergency responders participated in the firefighting and rescue operations, with 117 fire-fighting appliances being deployed to the scene. A total of two ships’ crew and 15 emergency responders suffered injuries and were taken to hospital for observation or treatment. 9
1.3 ENVIRONMENTAL CONDITIONS During the cargo loading in Texas and during passage in the Caribbean, the average air and sea temperatures experienced by Stolt Groenland were about 30°C, peaking at 37°C air temperature during the day. These averages reduced to about 25ºC during the passage across the Pacific Ocean. In Kobe, the sea temperature was 26ºC and the maximum and minimum air temperatures were 30ºC and 28ºC. In Ulsan, the sea temperature was 24ºC with maximum and minimum air temperatures of 25ºC and 19ºC. 1.4 ON-SITE INVESTIGATION On 28 September, the Maritime Authority of the Cayman Islands requested the MAIB investigate this accident in accordance with the International Maritime Organization (IMO) Casualty Investigation Code (IMO Resolution MSC 255(84)). During the on-site investigation in Ulsan, the MAIB was assisted by the Korea Maritime Safety Tribunal (KMST). Access to Stolt Groenland was controlled by the Korea Coast Guard and restricted by the toxicity of the atmosphere on board. On 3 October, with the co-operation of Bow Dalian’s owners and the Transport Safety Investigation Bureau of Singapore, MAIB inspectors and KMST staff visited Bow Dalian in Ulsan. The tanker’s weather decks and accommodation block were spattered with burned residues (Figure 7). A sample of residue (Figure 8), and the overalls (Figure 9) from a crewman who had been on deck during the period of vapour release from 9S’s p/v valve, were removed for analysis (see Section 1.20). On 7 October, the analysis of samples of styrene monomer taken from Stolt Groenland’s cargo tanks 6C and 6P indicated that the concentrations of the inhibitor 4-tert-Butylcatechol (TBC) were 8 parts per million (ppm) and 7ppm respectively. The following day, MAIB inspectors were allowed access to the vessel. However, the presence of hazardous chemicals and fire damage limited the inspection to the main deck primarily. A further inspection on 12 November was co-ordinated by the Korea Coast Guard and the KMST. These inspections, and inspections conducted by or on behalf of Stolt, confirmed that the heating coils in 9C and 9S were closed and blanked (Figure 10), and that vapours released from the p/v valves for 9S and 9C had ignited. 1.5 DAMAGE A large hole was found in Stolt Groenland’s main deck in way of cargo tank 9S and its common bulkhead with cargo tank 9C (Figures 11 and 12). The access hatch cover to 9S had also been blown off (Figure 13). The manifold area was fire damaged to varying degrees, and the midships deckhouse was burned out (Figure 14). The tanker’s accommodation block sustained extensive internal fire damage (Figure 15). The deck between the technical room and the CCR had collapsed, and both spaces were burned out. Heat and smoke had also penetrated the bridge and damaged much of its equipment. Other than broken windows, many of which were broken by firefighters during the emergency response, external damage to the front of the accommodation block was minimal (Figure 16). 10
1.6 ONBOARD RECORDS Cargo-related records and voyage related records such as ‘noon reports’ were available on ‘Veslink’, a networked system that was used on board Stolt Groenland to store data and to communicate with interested parties ashore. In addition to mandated information, Stolt Groenland’s voyage data recorder (VDR) recorded cargo tank levels, volumes, temperatures, and liquid densities. All cargo-related records (digital and paper) that were held in the CCR and the cargo samples stored in the midships deckhouse were destroyed in the fire. However, the cargo temperature data from 0001 (UTC) on 30 August to 0150 (UTC) on 28 September (Figure 17), the time range of the data that was available, was recovered from the VDR. Figure 7: Bow Dallian main deck with burned styrene deposits Figure 8: Styrene residue sample Figure 9: Overalls from Bow Dallian crewman 11
1.7 STYRENE MONOMER 1.7.1 Description Styrene monomer (also known as ethenylbenzene, phenylethylene, phenylethene, vinylbenzene, or cinnamene) is an aromatic hydrocarbon and a building block of the plastics industry. It is commonly used in the manufacture of a variety of plastic, rubber and polystyrene products. Over 30 million tonnes of styrene are produced annually, much of it transported by sea to plastics production plants. Styrene monomer is a colourless, transparent liquid under ambient conditions and has a distinctly sweet odour. It is a volatile and flammable substance with a flashpoint of 32ºC. Its boiling point is 145ºC and its auto ignition temperature is 490ºC. The harmful effects of styrene monomer include severe irritation to eyes and mucous membranes, as well as gastrointestinal effects. Chronic exposure to styrene monomer leads to central nervous system dysfunction, such as headache, fatigue, weakness, depression, hearing loss and nerve damage. Figure 10: 9S heating control valves 12
9C cargo tank area Approximate area of tank split (at deck level) 9S cargo tank area Figure 11: Aerial view of main deck and location of 9S 13
Polymerised styrene Figure 12: 9S tank rupture Figure 13: 9S access hatch 14
Figure 14: Midships deckhouse Figure 15: Accommodation interior 15
Figure 16: Accommodation front 1.7.2 Polymerisation Polymerisation is a chemical reaction, or process in which a monomer or a mixture of monomers is converted into a polymer such as polystyrene. Styrene polymerises slowly at normal ambient temperatures but very rapidly at elevated temperatures. It can be accelerated by heat, the lack of dissolved oxygen, the lack of a polymerisation inhibitor, and when contaminated by oxidising agents and most halides. The polymerisation process is exothermic and, if the resulting heat is not removed, the bulk styrene temperature may rise to a level at which polymerisation is self-sustaining and very rapid. This is referred to as ‘runaway polymerisation’ and will usually be initiated by temperatures above 65°C. During a runaway polymerisation, the cargo will expand causing pressure to increase to the point that vapour is released from tank vents or p/v valves. In some cases, the resulting build-up of pressure is sufficient to rupture the tank. 1.7.3 Polymerisation inhibitors To prevent polymerisation during storage and transportation, an inhibitor must be added. TBC, the most commonly used polymerisation inhibitor, is a solid but is often mixed with methanol to produce a liquid before adding to styrene monomer. In shore storage facilities, TBC is added to styrene monomer through dosing systems. For the marine transportation of styrene monomer in bulk, the TBC is added to the bottom of a cargo tank before loading. TBC should be stored in non-reactive, light resistant containers at ambient temperature. It is not known to have a limited shelf life. 16
Stolt Groenland cargoChart tank Title temperatures 100.0 August September Kobe, Japan Ulsan OTK YMP 90.0 30 31 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6P-16 80.0 Heating applied 9S - styrene monomer >1°C temp rise each day 6C-17 6S-18 Temperature ºC Heated HMD cargo in 9S styrene 7P-19 70.0 70.0 tanks 8P, 9P, 10P and 11P monomer 7C-20 temp 65° 7S-21 8P-22 Heated cargo in 7S 8C-23 60.0 60.0 8S-24 9P-25 9C-26 50.0 50.0 9S-27 10P-28 10C-29 40.0 40.0 10S-30 11P-31 11C-32 30.0 30.0 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 06h 12h 18h 00h 11C-32 30 30 30 30 31 31 31 31 01 01 01 01 02 02 02 02 03 03 03 03 04 04 04 04 05 05 05 05 06 06 06 06 07 07 07 07 08 08 08 08 09 09 09 09 10 10 10 10 11 11 11 11 12 12 12 12 13 13 13 13 14 14 14 14 15 15 15 15 16 16 16 16 17 17 17 17 18 18 18 18 19 19 19 19 20 20 20 20 21 21 21 21 22 22 22 22 23 23 23 23 24 24 24 24 25 25 25 25 26 26 26 26 27 27 27 27 28 Aug Aug Aug Aug Aug Aug Aug Aug Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Sep Figure 17: Cargo temperatures recorded on the VDR 17
The TBC level must be maintained within a specified concentration range, typically between 10-15ppm, to prevent polymer formation. The presence of dissolved oxygen is required for the inhibitor to function properly and it is the inhibitor that controls oxygen depletion. Where ambient temperatures are likely to exceed the flash point of the cargo, it might be desirable to use a nitrogen blanket to minimize the risk of fire or explosion. However, the atmosphere above styrene monomer should contain 3% to 8% (volume) of oxygen to maintain inhibitor effectiveness and therefore avoid polymerisation. Whether stored under air or a nitrogen blanket, the inhibitor concentration is depleted more rapidly at elevated temperatures. Consequently, styrene monomer is usually kept below 30°C when transported and below 20°C in storage tanks ashore. 1.8 CARGO SYSTEM Stolt Groenland was built in 2009 and was one of six sister vessels. The tanker had 39 integral cargo tanks of varying capacities, which were separated into three fore to aft sections by two transverse cofferdams. The tanks in the fore and aft sections (tanks 1-3 and 12-13) were constructed of zinc coated mild steel; the mid-section (tanks 4-11) was of solid duplex stainless steel construction. The tanks’ bulkheads were corrugated. All stainless steel tanks were fitted with heating coils, capable of maintaining a temperature of up to 85°C. The heating medium was water, and the system was controlled manually via valves on deck. Each cargo tank was independent and had its own pump and pipeline arrangement. The tanks were protected against over and under pressures by individual p/v relief valves, which were situated at two vent stacks on the main deck. The lifting pressure of the p/v valves was 206mb. Tank liquid levels were measured by a closed radar system, and tank pressures and temperatures by internal sensors. The temperature sensors were located at low and middle levels in each tank. Data from the radar and tank sensors was monitored via an Ariston computerised cargo monitoring system in the CCR (with a slave display on the bridge). The data was also fed to the vessel’s CargoMax stability computer. The information displayed by the Ariston system on the cargo monitor screens was determined by user preference. The system could be configured to show individual tanks or groups of tanks. The user was also able to set cargo level, temperature and pressure alarms for each tank. Stolt Groenland’s crew could not test or monitor for TBC concentration, oxygen or polymer levels in the styrene monomer cargoes. These values could only be determined in shore laboratories. 1.9 LOADING IN HOUSTON 1.9.1 Planning and documentation The cargo stowage plan for the loading between 2 and 17 August was first sent to Stolt Groenland by the tanker’s shore-based ship operator (see Section 1.11) on 19 July. Inconsistencies between the voyage cargo report (VCR) and the vessel’s iStow Tanker (iStow) cargo stowage computer, were raised by the C/O. These were subsequently addressed by the ship operator, and the plan was re-issued. Following further iterations of the plan, during which the intended stowage of the styrene monomer cargo was amended from cargo tanks 6P, 6C, and 10S, to 6P, 6C and 9S, 18
a final iStow file and VCR was issued by the ship operator on 1 August. The plan was checked and agreed by Stolt Groenland’s C/O and approved by the tanker’s master. The VCR listed the nominated cargoes for the forthcoming voyage. It also cross- referenced the bill of lading number with the chemical name, quantity, ports of loading and discharge, cargo-handling requirements, and safety references. It included: 430 STYRENE MONOMER Generic specs: HANDLING UPDATED 10 JUL 18 FOR SHELL REVISION 9 DATED 01 APR 18 HEAT ADJ NO HEATED CARGO TO BE STOWED ADJACENT. IMO Ships carrying this product must be provided a Certificate of Protection (Inhibitor Certifcate) from the shipper in order to comply with the requirements of 15.13.3. 1) Name and amount of additive/inhibitor 2) If additive is Oxygen dependent 3) Date additive was added to cargo and duration of effectiveness 4) Temperature limitations affecting effective lifetime of additive 5) Action that needs to be taken should voyage exceed effective lifetime of additive or a statement concerning the Oxygen level required if the exclusion of air method is being used to stop oxidization as per 15.13.4. If an Inhibitor Certificate is to be issued it MUST state if the Inhibitor is Oxygen Dependent, or not, and if it is Oxygen Dependent it MUST state the Oxygen level which will allow the inhibitor to be effective. If you do not receive this documentation please alert your Ship Operator as soon as possible. IBC Code 15.19.6 High Level alarm in cargo tank IBC Code 16.6.1 NO ADJACENT HEAT as this cargo can potentially go into a state of POLYMERIZATION, DECOMPOSITION. THERMAL INSTABILITY OR EVOLUTION OF GAS IBC Code 16.6.2 HEATING COILS IN TANK(S) loading this cargo MUST BE BLANKED OFF IMO Name STYRENE MONOMER INCOMPAT Polymerization catalysts. Strong oxidizing agents. The Shell document referred to in the VCR was their Cargo Handling Sheet for styrene monomer, which was intended for use by vessels chartered by Shell Chemicals. It included: Loading Temperature Range: 13 – 23 °C / 55 – 73 °F Transit Temperature Range: Ambient Discharge Temperature Range: Ambient 19
Maximum Heating Coil Temperature: Blanked Off Adjacent Maximum Cargo Temperature: 35°C Note 1: This product is heat sensitive, self-reactive and inhibited. Note 2: Shell Chemical SM is generally inhibited with Para-tertiary Butyl Catechol (p-TBC), typically at 10-20 ppm or more, depending on duration of voyage. Where required to add additional inhibitor to a loaded tank of styrene, this should be done using closed equipment. If the equipment is not available and there is a requirement to add inhibitor, the local Chemical MTA should be consulted. DAILY LOG: During the voyage the vessel shall maintain a daily log of the following and, upon request, send the log to the responsible Shell Chemicals Charterer: 1. cargo (Styrene) temperature 2. adjacent cargo temperature 3. air and sea water temperature If during the voyage any of the following is observed, the responsible Shell Chemicals Charterer shall be notified immediately: ● 1 °C rise of cargo (styrene) temp per day, over 3 consecutive days ● > 2 °C rise of cargo (styrene) temperature within any 24 hours ● Cargo temperature at any time raises above > 30°C ● O2 content in cargo (styrene) tank ≤4% by volume, when inerted After completion of cargo (Styrene) discharge the vessel shall provide a copy of the daily log of temperature/pressure/O2 content to the responsible Shell Chemicals Charterer. Due to risk of polymerization, Styrene should not be carried in tanks serviced by a cargo pump room. 1.9.2 The cargo The styrene monomer carried on board Stolt Groenland was supplied by Ineos Styrolution America LLC to the LBC Terminal in Houston, USA. The cargo was pumped from shore tank B503 (ST B503) to the tanker during 7 and 8 August 2019 and was designated as cargo OBL430. The charterer on the Bill of Lading was Samsung C&T Corporation. Prior to loading, the cargo tanks 6P, 6C and 9S had passed wall wash tests and visual inspections conducted by a cargo surveyor from American Cargo Assurance (ACA), and a preloading acceptance certificate was issued. 20
During the afternoon of 7 August, the ACA cargo surveyor and Stolt Groenland’s C/O completed a preloading checklist and exchanged cargo documentation which included a safety data sheet (SDS) for styrene monomer (stabilised) issued by Ineos Styrolution. Shortly afterwards, the surveyor carried out a final visual check of 6P, 6C, and 9S and then poured 3 US gallons (11.4 litres) of liquid inhibitor TBC into each of the tanks through their respective cleaning hatches. The addition of the inhibitor was witnessed by a terminal representative. No inhibitor was provided to the tanker’s crew to carry on board during the voyage. The loading of the styrene monomer started at 1735 (UTC-5) on 7 August from one shore cargo hose. The hose was connected to the tanker’s manifold via a splitter spool piece connected to tanks 6P and 6C. A cross-connection on the manifold also enabled the simultaneous loading of cargo tank 9S. The temperature of the styrene monomer stored in ST B503 was 13ºC. Between 0146 and 0340 on 8 August, pumping was stopped while awaiting the results of the shoreside testing of styrene samples from the cargo tanks. The analysis did not identify any issues, and loading was completed by 1520. The observed temperatures of the styrene monomer in Stolt Groenland’s cargo tanks shortly after the loading was completed ranged between 16.7 and 17.2ºC. At 1550, the ACA surveyor sealed the access and cleaning hatches for cargo tanks 6P, 6C and 9S. He then issued a Certificate of Inhibitor (Figure 18), which was signed by the attending terminal representative and Stolt Groenland’s C/O. This stated that the ideal temperature for the cargo was 60-85ºF (15.5-29.4ºC) and that if these conditions were exceeded, the cargo should be monitored for the inhibitor level and polymerisation, adding additional inhibitor as needed. 1.9.3 Styrene and inhibitor mixing The TBC liquid added to the tanks before cargo loading was thick and viscous, and its mixing with the styrene monomer relied on the agitation achieved during the loading process and the sloshing caused by vessel movement on passage. The partial agitation caused by the flow of the styrene monomer cargo as it loads into the tank was not sufficient to adequately mix the TBC with the styrene cargo. For this reason, TBC concentration tests, done both during and immediately after loading were prone to inaccuracy, and were therefore not undertaken. Instead, calculations were conducted and the notation ‘adjusted to XX ppm’ was used in the shipment analysis reports. This process was standard industry practice for styrene bulk transportation by sea. 1.9.4 Styrene sampling During the loading of the styrene monomer, the ACA surveyor took 1 US pint (0.47 litre) samples of the cargo on opening ST B503 from the dock-line, the cargo manifold and the 6P, 6C, and 9S pump stacks. The surveyor also took samples from each tank at the first foot1 and the final levels. The surveyor passed the samples to the C/O and these were then stored in the midships deck housing. The surveyor also sent a sample from ST B503, and cargo tank samples to an Ineos laboratory ashore for testing. The samples from 6P, 6C and 9S were combined for both the first foot and final levels, and were tested as composite samples. 1 The ‘first-foot’, or about 30cm, of loaded cargo was sampled to check if the cargo pipeline system was clean. 21
Figure 18: Certificate of Inhibitor 22
The Styrene Shipment Analysis report concerning the composite final sample (Figure 19) stated that the TBC concentration was adjusted to 17ppm and the Certificate of Inhibitor stated that the ‘Days Effective’ was 60-90 days. The concentration level was a calculation based on the TBC concentration in ST B503 (11.3ppm) and the amount of inhibitor that was added into the tanks prior to loading. 1.10 CARGO TEMPERATURE CHANGES DURING THE VOYAGE Stolt Groenland’s styrene monomer cargo was due to be discharged in An-Ping, Taiwan about 56 days after it was loaded in Houston. The VDR provided hourly cargo temperature records for the 30-day period prior to the explosion (Figure 17). At 1200 (UTC) on 30 August the recorded temperatures of the styrene monomer in 6P, 6C and 9S were 31.5, 31.4 and 37.2°C respectively. The temperatures of the HMD in 9P and the adiponitrile in 9C were 51.5 and 43.9°C respectively. The temperature variations recorded in cargo tanks 8P, 9P, 10P and 11P showed that the HMD had been routinely heated to about 55°C and then allowed to drop to about 45°C. This was achieved by opening and closing the heating coil valves; it typically took about 2 days to heat the HMD and 5 days to for its temp to drop. This weekly heating cycle resulted in temperature variations of about 2.5°C in 9C and 0.5°C in 9S. On 18 September, the heating coil valves for 8P, 9P, 10P and 11P were opened and the temperature was increased to about 55°C, where it was maintained ahead of the planned cargo discharge programme. At 1200 (UTC) on 18 September, the temperatures of the cargoes in 8S, 9S, 10S and 11S were 37, 37.7, 37.8 and 36.1°C respectively. The subsequent daily 1200 (UTC) temperatures of the starboard tanks are shown in Table 3. 8S midday 9S midday 10S midday 11S midday Dates temperature (°C) temperature (°C) temperature (°C) temperature (°C) 19 Sept 37.3 37.6 37.8 36.2 20 Sept 37.7 37.9 37.7 36.2 21 Sept 37.9 38.4 37.9 36.2 22 Sept 38.5 39.4 38.1 36.5 23 Sept 39.4 41.8 38.6 36.7 24 Sept 40.1 44.9 39.3 36.8 25 Sept 46.0 48.9 40.1 36.9 26 Sept 43.4 54.5 40.7 37.4 27 Sept 44.9 66.7 41.6 38.7 Table 3: Midday temperatures for tanks 8S, 9S, 10S and 11S between 19 and 27 September 2019 The temperature of the styrene monomer in 9S rose by 1°C on three consecutive days between 21 and 24 September and rose by 2.4°C between 22 and 23 September. It reached 65°C at about 1000 (UTC) on 27 September and 100.8°C immediately before the explosion. 23
Figure 19: Final sample analysis results 24
1.11 CREW 1.11.1 General Stolt Groenland’s crew comprised 10 officers and 15 ratings. The officers were Russian nationals and the ratings Filipino nationals. All crew held the appropriate STCW2 certification, including the chemical tanker basic training endorsement. The length of contract for the officers was 4 months. Two of the ratings were pumpmen, whose duties primarily concerned cargo operations. The master, senior officers and deck officers also had completed the STCW chemical tanker advanced training (see Section 1.15.2) within the last 5 years in accordance with Regulations V/1-1 and V/1 – 2. They viewed styrene monomer as a comparatively benign cargo when inhibited, and none had previously experienced problems with its carriage. 1.11.2 Master Stolt Groenland’s master had worked for Stolt since 1999, serving on a variety of ships. He had been a C/O for 5½ years and was promoted to master in 2009. Since 2016, he had been Stolt Groenland’s regular master, and prior to that he had served on its sister ships. The master last joined Stolt Groenland on 14 August 2019. 1.11.3 Chief officer (Ulsan) The C/O that joined the vessel in Ulsan started his career with Stolt in 2008 and had remained with the company throughout. He was promoted to second officer (2/O) in 2011, and to C/O in 2016. It was his fifth contract on Stolt Groenland, and he had also served on the vessel’s sister ships. 1.11.4 Chief officer (loading and voyage) The C/O that oversaw the cargo loading operation and completed the passage to Ulsan started his sea career as cadet in 2006 and worked on board oil tankers before joining Stolt as a 3/O in 2011. He was promoted to 2/O in 2012 and to C/O in 2017. The C/O had served as C/O on Stolt Groenland three times, usually with the same master and crew. He last joined the tanker in June 2019. 1.11.5 Voyage routines On passage, Stolt Groenland’s crew carried out watchkeeping duties and routine maintenance. The C/O worked days, supervising the deck crew and the pumpmen as well as completing administrative tasks and inspections. The C/O was responsible for monitoring the cargo and ensuring that the heated cargoes remained within the temperature ranges specified on the VCR. The adjustment of the heating controls to keep the heated cargoes within these parameters was delegated to one of the pumpmen. The second pumpman assisted with monitoring and maintaining pressures in the cargo tanks that had been protected with a nitrogen blanket. 2 International Convention on Standards of Training, Certification and Watchkeeping for Seafarers 1978, as amended (STCW Convention) 25
1.12 CARGO MANAGEMENT ASHORE Stolt was the world’s largest operator of chemical tankers, with a fleet of over 100 vessels. Cargo operations were co-ordinated from its main operations centres in Rotterdam, Houston and Singapore, and each vessel had a nominated ship operator who was responsible for cargo allocation and cargo loading and discharge programmes. The ship operator was the master’s shore-based point of contact for cargo-related issues. Stolt Groenland’s ship operator was based in Houston and was typically responsible for between four and five tankers at any one time. The ship operator had 23 years’ experience in the shipping industry and had worked for Stolt as a ship operator for 4 years, having initially completed 6 months’ on the job training under the supervision of an experienced manager. The ship operator used the iSTOW software, supported by Stolt’s ‘Chemscan’ database, to plan cargo stows. The database contained details of each chemical cargo, including temperature and nitrogen requirements, and enabled the iSTOW programme to identify inconsistencies in stowage plans related to aspects such as heated and cooled cargoes, heat in adjacent tanks, and cargo quality requirements. As a result, the iSTOW software informed the ship operator of the mix of cargoes a ship was able to carry. The user guide for iSTOW described the system as: …a computerized system that assists ship operators in the cargo stowing process. The system provides a “click, drag, and drop” feature for assigning of cargoes from a list to a cargo tank. STOW makes no attempt to stow the ship for the ship operator. Instead, it is a tool to assist the ship operator in the stow process and to alert them when any rules or regulations are violated. The system records stow changes made by the ship operator, sends and prints stow plans (including versions for last three cargoes and tank condition). Once the Stow Plan has been completed, the ship operator can ask the system to perform checks of the current Stow Plan. These checks use a combination of information from the Stolt CHEMSCAN Database and IMOS3. For example, if one of our customers has requested that we carry their cargo in a stainless-steel tank and that the adjacent cargoes are not heated above a certain temperature, the system will detect if there is a potential problem and alert the ship operator. Other checks are US Coast Guard compatibility, commingling, and last cargo restrictions. Additional checks are scheduled to be developed in compliance with changes in rules and regulations. On completion of verifying an intended cargo stowage plan in iSTOW, the ship operator forwarded the iSTOW file and the VCR to the vessel to check the viability of the stowage plan regarding factors including cargo compatibility, stability and trim. Stolt Groenland’s ship operator was aware of the potential for styrene monomer to polymerise and understood that the chemical should not be stowed adjacent to a heated tank. The ship operator assessed that the stowage of styrene monomer in 9S and the stowage of heated cargoes in 9P and 7S (i.e. separated by 9C and 8S) was acceptable. 3 Ship voyage management software. 26
1.13 ONBOARD CARGO PROCEDURES 1.13.1 Planning and stowage Stolt Groenland’s safety management system (SMS) included a cargo and ballast operations manual that provided guidance on the various phases of cargo operations. The standard operating procedures section of the manual included: Ship Operator stowage proposals as described in Cargo Orders Communication procedure are presented as proposals and must be closely studied taking into consideration the port and load berth rotation, draft, list, trim, loading sequence, etc. While operations try to give the Master maximum flexibility in making alterations, the Master and Chief Officer will often find that because of heating requirements, coating compatibility, tank sizes, pumps and cargo specifications, last cargo and customer requirements, there is often a limited choice of stowage. …It is the ship’s responsibility to make a detailed check of proper cargo stowage based on the proposal received from the Ship Operator. .. The final stow is always subject to the Master’s approval. No issues with the stowage of the styrene monomer cargo carried on board Stolt Groenland were raised by the tanker’s master or C/O. 1.13.2 Cargo monitoring The cargo and ballast operations manual also included: Care for the Customers cargo does not cease after loading, it continues throughout the voyage to the discharge port and during the discharge. Some cargoes may require additional attention and control during the voyage in respect to their single or combined concerns to: safety, quality, handling, cleaning, costumer’s demand etc. Ongoing cargo care is the most important aspect of the chemical tanker trade and the Chief Officer has the primary responsibility for conducting and recording these tasks… Voyage instructions required that the temperatures of cargoes requiring heating or cooling be recorded in a cargo temperature log at least once a day and for the log to be available for scrutiny by the receivers of the cargo at discharge ports. The instructions also required the temperatures of non-heated and non-cooled cargoes to be monitored for signs of abnormal activity such as polymerisation. There was no specific requirement for the temperatures of non-heated and non-cooled cargoes to be recorded. 1.14 IBC CODE SOLAS4 Chapter VII and MARPOL5 Annex II require chemical tankers built after 1 July 1986 to comply with the International Code for the construction and equipment of ships carrying dangerous chemicals in bulk and index of dangerous chemicals 4 International Convention for the Safety of Life at Sea, 1974, as amended. 5 International Convention for the Prevention of Pollution from Ships, 1973, as amended. 27
carried in bulk (IBC Code). In addition to prescribing design and construction standards, The IBC Code tabulates the minimum requirements for over 750 dangerous chemicals. References in the IBC Code to cargo temperature, inhibited cargoes, and cargoes not to be exposed to excessive heat, include: Chapter 7 – Cargo temperature control 7.1.5 Means shall be provided for measuring the cargo temperature. 7.1.5.4 When overheating or overcooling could result in a dangerous condition, an alarm system which monitors the cargo temperature shall be provided. (see also Operational Requirements in 16.6.) Chapter 15 – Special requirements 15.13 Cargoes protected by additives 15.13.3 Care shall be taken to ensure that these cargoes are sufficiently protected to prevent deleterious chemical change at all times during the voyage. Ships carrying such cargoes shall be provided with a certificate of protection from the manufacturer, and kept during the voyage, specifying: 1. the name and amount of additive present; 2. whether the additive is oxygen dependent; 3. date additive was put in the product and the duration of effectiveness; 4. any temperature limitations qualifying the additives effective lifetime; and 5. the action to be taken should the length of the voyage exceed the effective lifetime of the additives. Chapter 16 – Operational requirements 16.6 Cargoes not to be exposed to excessive heat 16.6.1 Where the possibility exists of a dangerous reaction of a cargo, such as polymerization, decomposition, thermal instability or evolution of gas, resulting from local overheating of the cargo in either the tank or associated pipelines, such cargo shall be loaded and carried adequately segregated from other products whose temperature is sufficiently high to initiate a reaction of cargo (see 7.1.5.4). 16.6.2 Heating coils in tanks carrying this product shall be blanked off or secured by equivalent means. 28
1.15 SHIPPING INDUSTRY GUIDANCE 1.15.1 Tanker Safety Guide The Tanker Safety Guide (2014) (TSG), was published by the International Chamber of Shipping to promulgate good practice. With reference to styrene monomer, the guide stated that polymerisation was very often initiated by elevated temperatures, which could reduce the effectiveness of the inhibitor or reduce the inhibitor’s effective life. It also stated: These inhibitors are designed to be effective for a set period of time at a specified temperature. It is therefore essential that the timed effectiveness of the inhibitor is sufficient for the voyage and includes a good safety margin. Since elevated temperature can reduce the effectiveness of the inhibitor, or reduce its effective life, it is essential that heat sources are kept away from these cargoes and that the temperature is closely monitored on at least a daily basis, or more frequently if recommended by the cargo manufacturer. An increase in cargo temperature that is not related to ambient weather conditions or adjacent cargo temperatures may be an early indication that a polymerisation process has started. In such instances, the cargo manufacturers should be contacted immediately to advise appropriate counter measures which may include the addition of more inhibitor or the cooling of adjacent structures. Should the increase in temperature be rapid then the decision to jettison cargo may be the only option in order to avoid serious structural damage to the cargo tank and the ship. Regarding cargo stowage and handling, the TSG included: ● That heated cargoes will be stowed so as to be compatible with cargoes in adjacent tanks; ● That heated cargoes will be stowed so as not to be adjacent to heat sensitive cargoes or when a heat source could lead to a dangerous reaction; ● Some cargoes require an inhibitor to ensure that they remain chemically stable during transit. Such cargoes should not be stowed adjacent to heated cargoes; ● Some cargoes are liable to self react under certain conditions…The temperature of cargoes that may self-react should be closely monitored. Unexpected changes are an early indicator of a possible self-reaction. Should the temperature rise be in excess of what is expected, taking into account the ambient conditions and the temperature of adjacent cargoes, then this should be treated as an emergency and handled accordingly… 1.15.2 Chemical Distribution Institute Guidance The Chemical Tanker Operations for the STCW Advanced Training Course – A Practical Guide to Chemical Tanker Operations (2018) was produced by the Chemical Distribution Institute (CDI) to provide an aide-mémoire for crews and a study guide for advanced training in chemical operations. 29
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